ML20195D952
| ML20195D952 | |
| Person / Time | |
|---|---|
| Site: | South Texas |
| Issue date: | 10/26/1988 |
| From: | Bundy H, Mckernon T, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20195D948 | List: |
| References | |
| 50-498-88-62, 50-499-88-62, NUDOCS 8811070201 | |
| Download: ML20195D952 (8) | |
See also: IR 05000498/1988062
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APPENDIX
U.S. NUCLEAR. REGULATORY COMMISSION
ItEGION IV
NRC Inspection Report:
50-498/88-62
Operating License:
50-499/88-62
Construction Permit:
CPPR-129
Dockets:
50-498
50-499
Licensee: Houston Lighting & Power Company (HL&P)
P.O. Box 1700
-Houston, Texas 77001
Facility Name:
South Texas Project (STP), Units 1 and 2
Inspection At:
Inspection Conducted: September 12-14, 1988 and October 10-14, 1988
Inspectors:
!aN~
/* he /rr
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T. O. McKetp6n, ReactorJInspector. Test
Date
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Programs Section. Division of Reactor Safety
b-
/* h l /tt
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H. F. BundyPReactor I'nspector, Test Programs
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Section, Division of Reactor Safety
b
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Iclu /tt
Approved:
W. C. Seidle,Mhief Test Programs Section
Date
Division of Reactor Safety
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Inspection Summary
inspection Conducted October 10-14, 1988 (NRC Inspection Report 50-498/88-62)
Area Inspected: Routine, unannounced inspection of followup to previously
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identified inspection concerns related to the quality control program.
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Results: Generally, the maintenance work request packages reviewed by the NRC
inspector satisfied the applicable requirements and were properly reviewed by
management for content and completeness.
No violations or deviations were
identified; however, an unresolved item concerning maintenance practices
relative to Unit I was identified, (paragraph 5).
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' Inspection Conducted September 12-14, 1988 (NRC Inspection Report 50-499/88-62)
Areas inspected: Routine, unannounced inspection of preoperational test
procedure review, preoperational test witnessing, location of manual trip
circuit, and fuel receipt.
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Results: Procedures reviewed satisfied applicable requirements. The
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preoperational testing witnessed by the NRC inspectors was performed in
accordance with the licensee's administrative procedures.
The manual trip
circuit was correctly located to perform its intended function. Fuel receipt
was properly performed in accordance with licensee procedures. No violations
or deviations were identified.
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DETAILS
1.
Persons contacted
HL&P
J. Westermeier, STP General Manager
- S. Head, Supervisor Project Engineer
K. O'Gara, Project Compliance Engineer
- M. Polishak, Lead Engineer, Project Compliance Group
0. Porter, Startup Engineer
D. Wahlhoim Startup Engineer
R. Thorin, Startup Engineer
B. Bealfield, Maintenance Technical Supervisor
- P. L. Walker, Licensing
- D. N. Brown, Construction
- W. J. Jump, Maintenance 'apervisor
- J. D. Green, Inspection and Surveillance Manager
- M. A. McBurnett, Licensing Manager
- M. R. Wisenberg, Plant Superintendent
NRC
D. Hunnicutt Senior Project Engineer
J. Tapia, Senior Resident Inspector, Unit 2
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J. Bess Senior Resident Inspector, Unit 1
"'*L. J. Callan, Director, Division of Reactor Projects, Rty
- E. Holler, Chief, ORP/D. RIV
The NRC inspectors also interviewed other licensee employees during the
inspection.
- Denotes those attending informal exit interview held on September 14,
1988.
A fonnal exit interview was not held at the conclusion of the
inspection of September 12-14, 1988, because of personnel unavailability
due to the Hurricane Gilbert watch.
- Denotes those attending exit interview conducted on October 14, 1988.
2.
Preoperational Test Procedure Review (70346)
The NRC inspector reviewed the following procedure to determine that it
satisfied regulatory requirements, final safety analysis report (FSAR)
comitments and industry standards.
2HF-P-02 Revision 0. TCN 1. "FHB HEPA/ Charcoal Filter Test"
It was also determined that it complied with licensee administrative
procedures.
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No violations or deviations were identified in the review of this program
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area.
3.
Preoperational Test Witnessing (70446)
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The NRC inspector witnessed completion of portions of the following test:
2HE-P-01, Revision 0. TCN 4. "EAB HVAC System"
Activities witnessed were perfomed in accordance with the Test Procedure
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and Startup Administrative Instruction 18 Revision 7. "Preoperational
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Testing."
No violations or deviations were identified in the review of this program
area.
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4.
Location of Manual Trip Circuits
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The purpose of this part of the inspection was to confim the correct
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location of the manual reactor trip circuits which are located downstream
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of Output Transistors 03 and Q4 in the UV output circuit. This will
prevent short-circuit failures of the automatic tripping of the associated
reactor trip breakers as described in NRC Infomation Notice 85-18. The
NRC inspector confirmed the correct location of the manual trip circuits
for both units from Bechtel Drawings 14926-0387(1)00171-BWN/
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14926-0387(2)00171-BWNand 14926-0387(1)00172-BWN/14926-0387(2)00172-BWN.
No violations or deviations were identified in the review of this program
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area.
5.
Followup to Previous Inspection Findings
(92701)
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This portion of the inspection involved the followup to quality control
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(QC) program concerns which, in part, were addressed in NRC Inspection
Report 50-498/88-52;50-499/88-52. The main effort of this inspection was
focused upon the review of maintenance work request packages (MWRs) for
adequate QC instructions, inspections, and reviews.
The MWRs listed in
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the attachment represent a review sampling of MWRs completed between March
and August 1988.
In the sample, greater weight was given to selecting
PWRs completed during August 1988.
During the review of the MWR packages, the NRC inspector noted that the
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licensee is effectively applying the requirements of ANSI N18.7-1976. To
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that effort, the licensee has established a program for the inspection of
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activities affecting safety.
Inspections, examinations, measurenents,
etc., are perfortned by qualified individuals in accordance with the
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requirements of ANSI N45.2.6.
In those instances, where inspections are
to be perfomed by qualified individuals other than the craftsmen perfoming
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the work, inspections are performed by the appropriate maintenance supervisor,
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systems engineer, or QC inspector. Generally, these practices are evidenced
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by incorporation of independent verification hold points, maintenance
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verification points (MVPs), quality verification / notation points (QVPs,
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QNPs), and quality inspection points (QIPs) into the work instructions.
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Although not all maintenance procedures contained the above types of
inspection hold points, the procedures generally provided evidence of a
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QC inspection sampling methodology. Applicable procedures, drawings,
specifications, standards, codes, and acceptance criteria were either
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specifically stated in the MWR package or specifically referenced.
The
work instructions indicated that the first-line craf tsmen and maintenance
section supervisors have responsibility for proper maintenance implementation
and cleanliness preservation. QC inspections (QNPs, QVPs, QIPs) are
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designated and incorporated into maintenance instructions during the
maintenance procedure development.
Determination of the specific types of
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QC inspections (e.g., torquing, cleanliness, clearances, lockwiring.
etc.) and their frequency is established by the QC department. The QC
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department makes the determinations based upon QC inspector availability,
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QC inspection essentit.lity, and problem trending. QC inspection instructions
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are either specifically stated in the maintenance procedures or specific
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reference is made to vendor technical manuals or controlling plant procedures.
Waivers of QC inspections are annotated in procedures with the waiving QC
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inspector's initial, date, and QC waiver number. Of those MWR packages
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reviewed, the NRC inspector noted three QC inspections were waived.
In
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subsequent review of QC documentation, it was found that during August 1-28,
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1988, 131 QC inspectior,s were scheduled. Of the 131 QC inspections, 124
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QC inspections were completed and 7 QC inspections waived. The NRC
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inspector noted no specific written guidance existed concerning the
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criteria for waiver.
Subsequent discussion with the QC manager revealed
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that, in general, QC inspection waivers were based upon inspector availability,
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QC inspection essentially, and priority of the maintenance evolution,
(i.e., critical path element).
Furthermore, it was noted that in those
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instances requiring postmaintenance testing, specific test instructions
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were either stated in the MWR package or specifically referenced.
Postmain-
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tenance testing results were independently reviewed and documented.
In general,
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the licensee's QC efforts appear to be adequate. Maintenance evolutions
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affecting safety-related structures, systems, or components appear to be
perfonned in a manner which ensures a quality level at least equivalent to
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that specified in the original design bases and requirements.
During the review of MWR packages, it was noted that certain inconsistencies
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exist between practices relative to simplified maintenance evolutions and
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more con' plex, detailed evolutions.
These inconsistencies are best characterized
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as "inattention-to-detail" items on the craftsmen's part in recording data
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and to the involvement of maintenance section supervisors and QC personnel
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in review of MWR packages for completeness,
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The NRC inspector noted, as an example, MWR IL-49553, "Electrical
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Penetration #EP-62 " corrpleted July 3, 1988. The MWR documents that the
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penetration failed an in-service leak test (ISLT).
However, the MWR
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package did not specifically reference the repair MWR or the postmaintenance
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ISLT. The NRC inspector discussed this matter with key licensee personnel
and stressed the importance of detailed documentation.
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The licensee agreed that inclusion of specific references in the work
package facilitates ready tra eability. A subsequent review of documentation
by the licensee retrieved records of postmaintenance testing from the
onsite document control center.
In this regard, the NRC inspector noted
that no specific guidance exists in the licensee's MWR Program
Procedure OPGP03-EM-0003, Revision 19, which delineates what the cognizant
maintenance division foreman should check when reviewing an MWR package
for completeness.
The NRC inspector noted that the QC procedure for
closure of MWRs/PMCs/SWRs included a checklist used by operations quality
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assurance during the final package review.
During review of MWR Package RH-57765, the NRC inspector noted that the
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craftsmen failed to document the heat number for the No. 4 removed stud.
Recording the heat numbers of removed studs wu required by Step 18 of the
ASME Section XI repair and replacement traveler, R&R No 1-88-019. The
failure to record the heat number is a concern that shall be identified
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as an unresolved item (50-498/8862-01) pending further investigation by
the licensee. Other similar examples of inattention-to-detail and
inadequate review were provided to the licensee. The NRC inspector
discussed the inconsistencies with the licensee and indicated that such
inconsistencies may be representative precursors to possible future
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program.atic problems.
6.
Receipt of New Fuel at Reactor Facilities
(81403) and (60502)
This portion of the inspection involved observation of the licensee's
procedural implementation for receipt of new fuel. The NRC inspector
verified that the licensee's physical security program provided satisfactory
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protection for new fuel upon receipt.
Furthermore, the NRC inspector
verified that the new fuel was inspected, assembled and stored in preparation
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for fuel loading in accordance with regulatory requirements, and FSAR
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commitments, license requirements, and procedural controls. The NRC
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inspector observed craf tsmen and QC personnel unpacking new fuel bundles,
perfonning visual inspection, and moving the new fuel bundles into temporary
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storage while awaiting fuel loading. The licensee had established precautions
and the necessary measures to satisfy 10 CFR 73.67 and provided adequate
physical protection of the new fuel bundles while in transit.
Procedural
controls were implemented for radiological controls to minimize personnel
exposure and to limit and control foreign material in and around the fuel
assembly storage area. Unit 2 fuel handling building.
The responsible
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craftsmen established a foreign material exclusion (FME) area, controlled
entry of personnel, tools, and equipment by use of a control log.
The use
of protective clothing and lanyarding of loose tools / items further prevented
loss of FME or possible damage to new fuel.
The NRC inspector noted that
key personnel present during the new fuel receipt and storage were knowledgeable
of the procedural requirements and cautious in their actions.
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No violations or deviations were identified in the review of this program
area.
7.
Exit Interview
The NRC inspectors met with the licensee personnel denoted in paragraph 1
on September 14, 1988 and October 14, 1988. The NRC inspectors sunrnarized
the scope and findings of the inspection. The licensee did not identify
as proprietary any of the infonnation provided to, or reviewed by the NRC
inspectors.
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Attachmer.t
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MWR packages reviewed:
HC-65955
RC-55463
DG-68864
DJ-45043
PE-56110
BR-87031683
AF-59855
PL-49058
RH-65259
AF-87033311
RH-65257
PK-68821
PL-65095
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PM-87024920
IL-49553
MS-59785
CM-66903
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RC-68875
BR-55515
DG-55348
PK-68305
CV-69934
RH-57765
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HS-66210
DG-68862
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CV-65863
DG-87033314
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AF-69673
DG-52064
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FP-87027058
RH-57764
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HE-59850
EW-58795
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